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HMRC internal manual

International Manual

HM Revenue & Customs
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Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: The basic rule


Chapter 5 is the CFC charge gateway for non-trading finance profits for the purpose of determining the CFC charge in accordance with Chapter 2 (see in particular TIOPA10/S371BA(3)(a)). The profits are any non-trading finance profits that are included within the CFC’s assumed total profits for the accounting period, so far as they fall within any of TIOPA10/S371EB to 371EE. These sections apply where the CFC has non-trading finance profits that are derived from:

  • assets and risks in relation to which any relevant significant people functions (SPFs) are carried out in the UK;
  • capital investment from the UK;
  • specified arrangements in lieu of dividends (typically loans) with the UK;
  • UK finance leases.